Customer Privacy Policy

Introduction

Devolro Group LLC. and its affiliates (“Devolro”) respect your concerns about privacy. This Privacy Policy explains Devolro’s policies and procedures regarding personal and other information about our customers. Devolro intends to provide you with a level of comfort and confidence in how we collect, use, disclose, and safeguard personal and other information that we collect or that you provide to Devolro. This Privacy Policy also explains how you can contact us if you have any questions or concerns.

This Privacy Policy describes our practices in connection with information that we collect through our websites, software applications, social media pages, e-mail messages, and your purchase or use of your Devolro vehicle, or personal information that you otherwise provide to Devolro. By providing personal information to us or by using our products or services, you agree to the terms and conditions of this Privacy Policy.

Personal Information That We May Collect

This Privacy Policy applies to personal information, which is information that can be used to contact or identify you. Personal information includes your name, home and business mailing addresses, telephone number, e-mail address, payment card, direct debit (ACH) or other billing information, social media account identification, driver’s license number, tax identification number, government-issued identification number, fapiaos in Asia, date of birth, and certain data about your Devolro vehicle (as described below in more detail).

We may collect personal information in a variety of ways, including:

Through the Services: We may collect personal information through our websites, software applications, social media pages, e-mail messages, or other digital services (the “Services”), e.g., when you sign up for a newsletter or make a purchase.

From other sources: We may receive your personal information from other sources, such as public databases, joint marketing partners, and social media platforms.

Devolro Club: Customers who purchase a Devolro vehicle will receive a Devolro Club account, which is hosted on our website. We may collect and process the following types of data for your Devolro Club account that you elect to provide to us: your customer registration information; the status of your vehicle order; warranty and other documentation for your vehicle; and general information about your vehicle (including vehicle identification number, production plan information, concierge service, and other personalized details), insurance forms, driver’s licenses, and financing agreements.

Telematics Log Data: To improve our vehicles and services for you, we collect certain telematics data regarding the performance, usage, operation, and condition of your Devolro vehicle, including the following: vehicle identification number, speed information, odometer readings, battery use management information, battery charging history, electrical system functions, software version information, infotainment system data, safety‐related data (including information regarding the vehicle’s SRS systems, brakes, security, e‐brake), and other data to assist in identifying and analyzing the performance of the vehicle. We may collect such information either in person (e.g., during a service appointment) or via remote access.

Remote vehicle analysis: We may be able to dynamically connect to your Devolro vehicle if requested to diagnose and resolve issues with it, and this process may result in access to personal settings in the vehicle (such as contacts, browsing history, navigation history, and radio listening history). This dynamic connection also enables us to view the current location of your vehicle, but such access is restricted to a limited number of personnel within Devolro.

Other vehicle data: In order to help improve our products and services, we may collect and store data about accidents involving your Devolro vehicle (such as air bag deployment) and the following types of data: data about remote services (such as remote lock/unlock, start/stop charge, and honk-the-horn commands); a data report to confirm that your vehicle is online together with information about the current software version and certain telematics data; data about any issues that could materially impair operation of your vehicle; data about any safety‐critical issues; and data about each software and firmware update. We may collect such information either in person (e.g., during a service appointment) or via remote access.

Service history: We may collect and process data about the service history of each Devolro vehicle, including the customer’s name, vehicle identification number, repair history, any outstanding recalls, any bills due, any customer complaints, and any other information related to its service history.

Offline: We may collect personal information from you offline, such as when you visit a Devolro store or repair facility, attend one of our tradeshows, sign up for a test drive, place an order over the phone, or contact our customer services or sales department.

How We May Use Personal Information

We control access to personal information, including taking steps to restrict access to personal information to individuals within Devolro who need such information to perform their jobs and are bound by enforceable confidentiality obligations. We may use personal information for a variety of reasons, such as those listed below:

To respond to your inquiries and fulfill your requests, such as to send you newsletters or product information, vehicle information alerts, or brochures.

To set up, evaluate, and provide feedback regarding a test drive.

To complete and fulfill your purchase, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase, and provide you with related customer service.

To provide service to your Devolro vehicle, including to contact you with service recommendations and to deliver over-the-air updates to your vehicle.

To advise you of important safety-related information.

To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies.

How We May Share Personal Information

Personal information we collect may be disclosed to third parties when necessary to perform services on our or on your behalf, including the following:

To Devolro affiliates for the purposes described in this Privacy Policy. Devolro affiliates are companies that are owned or controlled by Devolro Group LLC. and companies in which Devolro Group LLC. has a substantial ownership interest.

To our third party service providers to provide services such as website hosting, data analysis and storage, payment processing, order fulfillment, wireless connectivity to Devolro vehicles, information technology and related infrastructure, customer service, vehicle maintenance or related services, e-mail delivery, credit card processing, auditing, marketing, and other similar services.

To third party service centers if you choose to utilize them. Note that some personal information is stored on the Devolro vehicle and may be accessible directly to the third party service centers that you choose to utilize to diagnose or service your vehicle.

To other third party business partners to the extent that they are involved in your purchase or the service of your Devolro vehicle or related products. We share limited personal information to allow you to take advantage of those services if you elect to utilize them, with such partners as finance, leasing, registration, and title companies.

To third-party sponsors of contests and similar promotions, if you elect to participate.

To your employer or other fleet operator or the owner of the Devolro vehicle, if you do not directly own it and as authorized under applicable law.

To your social media account provider, if you connect your Services account and your social media account. If you do so, you authorize us to share information with your social media account provider and you understand that the use of the information we share will be governed by the social media account provider’s privacy policy.

To a third party in connection with any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

Devolro may transfer and disclose information, including personal and non-personally identifiable information, to third parties to comply with a legal obligation (including, but not limited to, subpoenas); when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our policies and procedures; to respond to an emergency; to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable; or to protect the rights, property, safety, or security of the Services, Devolro, third parties, visitors to our Services, or the public, as determined by us in our sole discretion.

We do not share your personal information with unaffiliated third parties for their marketing purposes unless you opt in to that sharing.

How We May Collect or Share Information That Does Not Personally Identify You

We may also collect and share information that cannot, on its own, be used to identify you. We and our third party service providers may collect such information in a variety of ways, including:

Through your vehicle: We may provide you with features in your Devolro vehicle, such as the real-time traffic feature, which make use of the true road segment speed of your vehicle, and we may share this data with partners that contribute similar data to help us provide the service. However, we only collect and share this data if these features are available in your vehicle and if you elect to use them, and we only collect and share this data in a way that does not personally identify you or your vehicle. We also do not collect the beginning or end of your trips. We also may collect similar data in connection with other features and may share it with business partners where necessary to provide the feature to you, but we will only collect and share the data in a way that does not personally identify you.

Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Services (such as the Devolro App) you are using. We use this information to ensure that the Services function properly.

Using cookies in connection with your Devolro Club account and our website: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other web traffic data. Our service providers and we use the information for security purposes, to facilitate online navigation, to display information more effectively, and to personalize your experience while using the Services, as well as for online tracking purposes. We can recognize your computer to assist your use of the Services. We also gather statistical information about the usage of the Services in order to continually improve their design and functionality, understand how the Services are used, and assist us with resolving questions regarding the Services. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and to display them to you. We may also use cookies in online advertising to track responses to our advertisements, and we may use cookies or other files to track your use of other websites.

If you do not want information collected through the use of cookies when using your Devolro Club account or our website, there is a simple procedure in most browsers that allows you to automatically decline cookies or gives you the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer, and you may need to log in every time you visit the applicable Services.

Website and application analytics: We use website and application analytics services provided by third parties that use cookies and other similar technologies to collect information about website or application use and to report trends, without identifying individual visitors. The third parties that provide us with these services may also collect information about your use of third-party websites. You can learn about Google’s practices in connection with this information collection and how to opt out of it by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Use of pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including e-mail recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates. Unless combined with personal information, this information does not personally identify you or any other user of the Services.

Except as described above, Devolro may use or share non-identifying information, such as for operational or research purposes, for industry analysis, to improve our products and services, to better tailor our products and services to your needs, and where legally required.

Links

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates, nor does it imply an affiliation with the third party.

Please note that we are not responsible for the collection, use, or disclosure policies and practices (including the data security practices) of other organizations, such as any other app developer, app provider, social media platform provider, operating system provider, or wireless service provider, including any personal information you disclose to other organizations through or in connection with our software applications or social media pages.

Security

We seek to use reasonable organizational, technical, and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section.

If you sell or transfer your Devolro vehicle to another person, please notify us so that we can determine whether additional steps are required to help safeguard your personal information from disclosure to the purchaser or transferee of the Devolro vehicle.

Rights and Choices

We give you many choices regarding our use and disclosure of your personal information. You may opt out at any time and free of charge from:

Receiving electronic communications from us or our affiliates: If you no longer want to receive marketing-related e-mails from us or our affiliates, you may opt out of receiving them by following the opt-out instructions in any e-mail received from us or by contacting us at the address below. Please note that we may still send you important administrative and safety messages even if you opt out of receiving marketing e-mails.

Receiving marketing-related calls from us: If you receive a marketing-related call from us and do not want to receive similar calls in the future, simply ask to be placed on our “do not call” list. Please note that we may still call you regarding administrative, safety, or vehicle service issues even if you opt out of receiving marketing calls.

Any processing of personal information for which you have provided your prior explicit opt-in consent by contacting us as indicated in the “How to Contact Us” section below.

Our collection of Devolro vehicle data. If you no longer wish us to collect Telematics Log Data or any other data from your Devolro vehicle, please contact us as indicated in the “How to Contact Us” section below. Please note that, if you opt out from the collection of Telematics Log Data or any other data from your Devolro vehicle, we will not be able to notify you of issues applicable to your vehicle in real time, and this may result in your vehicle suffering from reduced functionality, serious damage, or inoperability, and it may also disable many features of your vehicle including periodic software and firmware updates, remote services, and interactivity with mobile applications and in-car features such as location search, Internet radio, voice commands, and web browser functionality.

Our collection of real-time traffic feature data. We only collect this data if the real-time traffic feature is available to you and you elect to use it. If you no longer wish us to collect or share data from your vehicle for this feature, you can stop this collection at any time.

We will comply with your request(s) as soon as reasonably practicable.

Subject to applicable law, you may have the rights to request access to and receive information about the personal information we maintain about you, update and correct inaccuracies in your personal information, and have the information blocked or deleted, as appropriate. These rights may be limited in some circumstances by local law. We give you several methods to access, correct, update, or request blocking or deletion of your personal information including:

You can access your Devolro Club account to update the personal information in that account at any time.

If you would like to review, correct, update, suppress, or delete personal information that has been previously provided to us by you, you may contact us at the address below.

In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information that you have provided to us suppressed from our database, or otherwise let us know what limitations you would like to put on our use of your personal information that you have provided to us. For your protection, we may only implement requests with respect to the personal information associated with the particular e-mail address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Retention Period

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Minors

The Services are not directed to individuals under the age of sixteen (16), and we request that these individuals not provide personal information to Devolro.

Cross Border Transfers

The Services are controlled and operated from the United States. Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers. Those countries may not have the same data protection laws as the country in which you initially provided that information. When we transfer your personal information to other countries, we will protect it as described in this Privacy Policy. By using the Services or otherwise providing personal information to us, you consent to the transfer of personal information to countries outside of your country of residence, including the United States.

If you are located in the EEA or Switzerland, we comply with applicable legal requirements providing adequate protection for the transfer of personal information to countries outside of the EEA or Switzerland. Devolro Group LLC. comply to the EU-U.S. Safe Harbor Framework and the Swiss-U.S. Safe Harbor Framework as set forth by the U.S. Department of Commerce, European Commission, and Switzerland regarding the collection, storage, use, transfer, and other processing of personal information transferred from the EEA or Switzerland to the U.S. For more information about the Safe Harbor, please see http://www.export.gov/safeharbor/.

Updates to this Policy

We may change this Privacy Policy. Please take a look at the “Last Updated” legend at the bottom of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Services. By using the Services or otherwise providing personal information to us following these changes, you accept the revised Privacy Policy.

How to Contact Us

To contact us with a question or comment, to opt out from certain services, or to request access to, correction, or deletion of your personal information, please contact us: